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U.S. v. KILPATRICK

Crim. A. No. 82-CR-222.

726 F.Supp. 789 (1989)

UNITED STATES of America, Plaintiff, v. William A. KILPATRICK and Declan J. O'Donnell, Defendants.

United States District Court, D. Colorado.

November 2, 1989.

Attorney(s) appearing for the Case

David Barger, Alexandria, Va., Dana Boente, Tax Div., Crim. Section, U.S. Dept. of Justice, Washington, D.C., for plaintiff.

William A. Cohan, Denver, Colo., for defendant Kilpatrick.

Richard Stuckey, Denver, Colo., for defendant O'Donnell.

FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER

MATSCH, District Judge.

During the time relevant to these proceedings, the Internal Revenue Code (IRC) and Internal Revenue Service (IRS) regulations provided opportunities for individual taxpayers to attenuate their income tax liability by investments in programs oriented toward maximizing available deductions. Such programs were known as "tax shelters." Under the canopy of the IRC, an individual in a high...

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